PRIVACY POLICY OF IG BRANDS PTE LTD
1. INTRODUCTION
This is the privacy policy (“Privacy Policy”) of IG Brands Pte Ltd (“Company”, “we”, “us”, or “our”) which owns and operates the website www.geocolouredlenses.com.
In the course of your dealings with us, we will need to collect, use, disclose and process your personal data (including sensitive personal data). This Privacy Policy applies to personal data about our customers that we obtain now or in the future. We will only process your personal data in accordance with the Personal Data Protection Act 2010 (“PDPA”) as well as this Privacy Policy.
By providing your personal data to us or using our website, you declare that you have read and understood this Privacy Policy and agree to us processing your personal data in accordance with the manner as set out in this Privacy Policy.
We reserve the right to amend this Privacy Policy from time to time with reasonable prior notice to you. We will notify you of any amendments via announcements on the website or other appropriate means. By continuing to use our services, purchase our products using our website after being notified of any amendments to this Privacy Policy, you will be treated as having agreed to and accepted those amendments.
It is necessary for us to collect and process your personal data. If you do not provide us with your personal data, we may not be able to render all services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using the website.
2. COLLECTION OF PERSONAL DATA
The term “personal data” means any information that relates to an individual to the extent that the individual can be identified from that information such as name, address, telephone number, NRIC No, date of birth, email address, etc. “Sensitive personal data” means any personal data consisting of information as to the physical or mental health of the individual including prescription information.
Your personal data (including sensitive personal data) may be collected from you during your course of dealings with us in any way or manner including pursuant to any transactions or communications made with us including by way of email or fax.
3. PURPOSE OF ACQUIRING AND PROCESSING YOUR PERSONAL DATA
Your personal data (including sensitive personal data) may be processed for the following purposes (“Purposes”):
- to provide products or services to you;
- to verify your prescription information with your eye-care professional;
- to manage your relationship with us;
- to respond to your enquiries or complaints;
- to process any payments related to products or services requested by you;
- to perform customer due diligence checks pursuant to the requirements and rules prescribed under the Anti-Money Laundering and Anti-Terrorism Financing Act 2001 and by the Financial Intelligence Unit of Bank Negara Malaysia;
- to conduct credit reference checks and establish your credit worthiness, where necessary, in providing you with the products, services and/or facilities;
- to carry out due diligence or other monitoring or screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by us;
- to administer and give effect to your commercial transactions with us;
- to provide you with information and/or updates on our products, services, upcoming promotions offered by us and/or events organised by us and selected third parties which may be of interest to you from time to time by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
- to send you seasonal greetings messages, gifts, newsletters from time to time;
- to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;
- to share any of your personal data with the auditor for our internal audit and reporting purposes;
- to share any of your personal data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
- to share any of your personal data with a third party necessary for the preparation of legal documents or contract to be entered by you;
- to share any of your personal data with insurance companies necessary for the purpose of applying and obtaining insurance policy(ies), if necessary;
- to communicate with you and to maintain and improve customer relationship;
- to maintain and update internal record keeping, files and contact lists;
- to detect, investigate and prevent any fraudulent, prohibited or illegal activity or omission or misconduct;
- to enable us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
- to meet any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
- to comply with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory bodies or other similar authorities;
- to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
- for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
- for internal administrative purposes;
- for audit, risk management and security purposes;
- for registration for a user account with us;
- for our storage, hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia; and/or
- for other purposes required to operate, maintain and better manage our business and your relationship with us,
- and you agree and consent to us using and processing your personal data for the Purposes in the manner as identified above. If you do not consent to us processing your personal data for one or more of the Purposes, please notify us at the contact details below.
4. CONSEQUENCES OF NOT CONSENTING TO THIS PRIVACY POLICY
If you do not consent to us processing your personal data, we will not be able to provide our products or services or otherwise deal with you, if at all.
5. DISCLOSURE OF YOUR PERSONAL DATA
We will not sell or disclose any of your personal data (including sensitive personal data) to any third party without your consent. However, we may disclose your personal data to the following third parties, for any of the above Purposes:
- the Company’s group of companies including the Company’s subsidiaries, related and/or associated companies;
- your eye-care professional;
- any person under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge our obligations to you;
- our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business on a strictly confidential basis, appointed by us to provide services to us;
- any party nominated or appointed by us either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where we have a legitimate common interest;
- data centres and/or servers located within or outside Malaysia for data storage purposes;
- storage facility and records management service providers;
- payment channels including but not limited to banks and financial institutions for purpose of verifying and facilitating payment due to us in connection with your purchase of our products and/or services;
- to any government agency or body to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
- to perform customer due diligence checks pursuant to the requirements and rules prescribed under the Anti-Money Laundering and Anti-Terrorism Financing Act 2001 and by the Financial Intelligence Unit of Bank Negara Malaysia
- our business partners, third party product and/or service providers, suppliers, vendors, distributors, contractors or agents, on a need to know basis, that provide related products and/or services in connection with our business, or discharge or perform one or more of the above Purposes and other purposes required to operate and maintain our business;
- insurance companies for the purpose of applying and obtaining insurance policy(ies), if necessary;
- financial institutions for the purpose of applying and obtaining credit facility(ies), if necessary;
- financial institutions, merchants and credit card organisations in connection with your commercial transactions with us;
- any third party (and its advisers/representatives) in connection with any proposed or actual reorganization, merger, sale, consolidation, acquisition, joint venture, assignment, transfer, funding exercise or asset sale relating to any portion of the Company; and/or
- any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the activities set out in the Purposes or as instructed by you.
6. ACCURACY OF YOUR PERSONAL DATA
We take it that all personal data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us in the event of any change to your personal data.
7. YOUR RIGHTS
You have the right to request for access to, request for a copy of, request to update or correct, your personal data held by us.
You have the right to request us to stop sending you any marketing and promotional materials or contacting you for marketing purposes.
You also have the right, by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us. However, your withdrawal of consent could result in not being able to continue the contract that you have with us and it will have to be terminated.
8. RETENTION OF YOUR PERSONAL DATA
Any of your personal data provided to us is retained for as long as the purposes for which the personal data was collected continues; your personal data is then destroyed or anonymised from our records and system in accordance with our retention policy unless its further retention is required to satisfy operational, legal, regulatory, tax or accounting requirements.
If you are a US resident, we are required to retain your information for up to 3 years in accordance with the Fairness to Contact Lens Consumer Act and Contact Lens Rule.
9. SECURITY OF YOUR PERSONAL DATA
We are committed to ensuring that your personal data is stored securely. We endeavour, where practicable, to implement appropriate technical, physical, electronic and procedural security measures in accordance with the applicable laws and regulations and industry standard to safeguard against and prevent the unauthorised or unlawful processing of your personal data, and the destruction of, or accidental loss, damage to, alteration of, unauthorised disclosure of or access to your personal data.
We will make reasonable updates to its security measures from time to time and ensure the authorised third parties only use your personal data for the Purposes set out in this Privacy Policy.
We cannot and do not accept responsibility for any unauthorised access or interception or loss of personal data that is beyond our reasonable control.
10. TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF MALAYSIA
Our information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia. You hereby expressly consent to us transferring your personal data outside of Malaysia for such purpose. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your personal data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your personal data.
11. WEBSITE
External links
If any part of the website links you to other websites, those websites do not operate under this Privacy Policy and we do not accept any responsibility or liability arising from those websites.
Likewise, if you subscribe to an application, content or a product from our strategic partner and you subsequently provide your personal data directly to that third party, that personal data will be subject to that third party’s privacy/personal data protection policy (if they have such a policy) and not to this Privacy Policy.
We recommend you to read and understand the privacy/personal data protection statement/policy posted on those other websites in order to understand their procedures for collecting, processing, using and disclosing personal data and before submitting your personal data to those websites.
Cookies
We employ an industry standard technology called “cookies”. The cookie is a small piece of information stored on the hard drive of your computer or device for record-keeping purposes, and is used by us to track your visits to this website. Cookies are necessary on e-commerce websites to allow you to complete your purchase and payment. Third party advertising networks may issue their separate cookies to your hard drive when serving advertisements.
The type of anonymous click stream data collected by us through the cookies may include your Internet Protocol address, web browser software, date and time of visit to the website, and whether your requests (including search requests and clicking on links to parts of the website) were met with successfully. All such information collected through cookies are not personal data and you cannot be identified from this information. Such information is only used for the purpose of managing and creating a better user experience, analysing the traffic on the website and to identify areas for improvement on the website.
The use of cookies is now an industry standard, and you will find them used on most major websites. Most browsers are initially set up to accept cookies. If you prefer, you can reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. You should understand that certain features on the website will not function properly if you set your browser to not accept cookies.
12. CONTACT DETAILS
If you have any questions about this Privacy Policy, or have any further queries, or would like to make a complaint or data access or correction request in respect of your personal data, you may email us at care@geocolouredlenses.com.